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#2252939 - 04/26/21 02:44 PM Reg CC Exception Hold
danyielg Offline
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danyielg
Joined: Jun 2007
Posts: 437
OK
I'm curious to know if I'm the only person who thinks the Reg CC Exception Hold process is just craziness. I have a $24000.00 personal check deposit today...I have to do 4 different hold times. $225 the next business day, $450 the second business day, $4850 the third business day and the remaining $18475.00 I can hold until the 7th business day. How in the world does that make sense? I just see all kinds of room for errors and criticisms. Will I be in compliance it I only do the $4850 hold for 3 days and the balance for 7 days? I don't even pretend to understand this Reg. so please.....enlighten me. Or better yet...send me all of your tricks and cheat sheets.

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#2252981 - 04/26/21 09:41 PM Re: Reg CC Exception Hold danyielg
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You don't HAVE to include the case-by-case hold AND the exception hold (unless that's your bank's policy), and you may have made the process more complex than it needs to be.

Your bank might not disclose that it can made that strange $450 late day 2 release and hold the $4850 to the 3rd day. If that's the case, you'd have to combine those two amounts and release it the morning of day 2.

You can't hold the first $4850 to the third day. But you could make the first $5525 available on day 1 and hold the difference to day 7. The Reg allows you to make funds available sooner than required.

Yes, Reg CC is frustratingly complicated when combining hold types on a large check.
Last edited by John Burnett; 04/26/21 09:42 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#2252987 - 04/26/21 10:42 PM Re: Reg CC Exception Hold danyielg
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
I have yet to see a bank use the $450 day rule. I have worked for seven banks in my career and have only ever written polices/procedures for the CBC and exception holds. Don't make things so complicated. There are plenty of tools online. If you don't find one here, use cbancnetwork.
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TryingToComply
CRCM

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#2252991 - 04/27/21 11:35 AM Re: Reg CC Exception Hold danyielg
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
I agree with TryingtoComply - I too have not seen the $450 used as it really just complicates things. In fact, I've noticed a trend where some banks are trying to simplify things by avoiding case-by-case holds altogether and just focusing their efforts on exception holds.

Here are two hold resources from this site:
-Cheat Sheet: https://www.bankersonline.com/tools/151071
-Hold Calendar: https://www.bankersonline.com/tools/148338
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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